Siili Solutions

The role of the administrative, management and supervisory bodies

Board of Directors The duties of Siili's Board of Directors are determined in the Limited Liability Companies Act, according to which the Board of Directors shall see to the administration of the Company and the appropriate organisation of its operations and ensure the appropriate arrangement of the control of the Company's accounts and finances, in addition to which, the Board is tasked with monitoring and evaluating the organisation and internal control of sustainability reporting. Hence, the Board of Directors is also the highest-level body within the Company responsible for the management of sustainability and the appropriateness of activities. It adopts the Company's sustainability targets and monitors their achievement. Furthermore, the Board of Directors adopts Siili's Code of Conduct steering its activities and more detailed instructions based on it.

Sustainability has been integrated into the Company's long-term strategy adopted by the Board of Directors, long-term business plans, risk assessments and annual action plans. The Board of Directors monitors progress towards the sustainable development goals in its meetings, and adopts a sustainability report at least on an annual basis. After their meetings, the Audit Committee and the HR Committee report to the Board of Directors on sustainability topics discussed by them.

Board of Directors' sustainability expertise Siili's Board of Directors has actively participated in the double materiality analysis process, studied its results, and approved the determined materiality threshold and the final outcome of the process. The Board of Directors has actively monitored the preparation of the sustainability report and will monitor the execution on the sustainability targets to be established on a regular basis, at least annually. All members of Siili's Board of Directors are experienced in various management duties in sectors relevant to Siili, such as the IT and technology business, and many key customer sectors, including banking and finance as well as consumer business. Moreover, all members of the Board of Directors have served or are serving as board members in listed and unlisted companies. The educational background of the members is in technology, law, or business, and they have wide-ranging national and international expertise in the Company's sector, including AI and the data business. Members of Siili's Board of Directors also function in responsible positions at other companies that are obliged to prepare a sustainable development report.

Committees of the Board of Directors Siili's Board of Directors has appointed an Audit Committee and HR Committee from among its members to assist the Board of Directors in the preparation of matters. The Board of Directors has adopted charters for the Committees, which outline the main duties and operating principles of the Committees.

Siili's Audit Committee assists the Board of Directors in performing its supervisory duty regarding financial and sustainability reporting and control, risk management as well as internal and external audit. The Company's risk management also encompasses all material sustainability-related risks. In 2025, the Company integrate the risks identified in the double materiality analysis and their management into its business risk management processes.

The HR Committee prepares materials and provides advice on the personnel of the Company as well as matters related to the remuneration and incentives of the Company's management. The Committee is tasked with, among other things, reviewing the compatibility of the HR strategy and business strategy, the results of the job satisfaction survey, the performance of occupational safety and health enforcement, the diversity situation, as well as related plans and policies.

Chief Executive Officer, Management Team and employees' representation Siili's CEO steers and supervises the Company's business and is responsible for the day-to-day operational management of the Company, productisation as well as strategy implementation. The CEO also prepares matters for Board review is responsible for their implementation. The CEO is responsible for the promotion of the sustainability programme in accordance with instructions given by the Board of Directors. The CEO reports to the Board of Directors on sustainability-related material impacts, risks and opportunities, as well as progress towards sustainability targets.

Siili's employees are represented in the management team for the Finnish business by a staff representative. Siili does not have employee representation in other administrative or supervisory bodies.

Identity of the members of the administrative, management and supervisory bodies responsible for oversight of impacts, risks and opportunities

Gender diversity ratio of the bodies, percentage share of independent Board of Directors' members

Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies

In addition to the sustainability report, the Board of Directors receives all material sustainability‑related information, such as the results of the double materiality analysis and carbon footprint calculation. The Board of Directors monitors progress towards the sustainable development goals in its meetings, and adopts a sustainability report at least on an annual basis.

After their meetings, the Audit Committee and the HR Committee report to the Board of Directors on sustainability topics discussed by them. The Audit Committee monitors the outcomes of internal control and audits sustainability reporting practices as part of its audit duty. The HR Committee reviews the compatibility of the HR strategy and business strategy, the results of the job satisfaction survey, the performance of occupational safety and health enforcement, the diversity situation, as well as related plans and policies.

The CEO reports to the Board of Directors on sustainability-related material impacts, risks and opportunities, as well as progress towards sustainability targets. The Company's Management Team prepares matters related to sustainability before the CEO presents them to the Board of Directors and supervises, for its part, the implementation of sustainability actions as well as impacts, risks and opportunities related to sustainability at least on an annual basis in the meetings of the Management Team.

Integration of sustainability-related performance in incentive schemes

The remuneration policy for Siili's governing bodies is defined by the principles governing the remuneration of the Company's Board of Directors, chief executive officer and deputy CEO, if any. The remuneration policy has been prepared in accordance with the Shareholder Rights Directive ((EU) 2017/828), which is primarily implemented in the Finnish Limited Liability Companies Act (264/2006, as amended), the Securities Markets Act (746/2012, as amended), Decree 608/2019 of the Ministry of Finance and the Corporate Governance Code.

Siili's remuneration principles and the total remuneration of the administrative, management and supervisory bodies are described in more detail in the Remuneration Report and Remuneration Policy. The objective of the remuneration policy is to promote the Company's strategy, long-term financial success and the sustainable growth of shareholder value. Siili's sustainability targets or climate-related actions are not linked to the remuneration system.

Statement on due diligence

Siili has integrated compliance with the due diligence obligation into its corporate governance, strategy and administration, which adheres to the Finnish Corporate Governance Code for listed companies. Moreover, Siili has considered material sustainability topics in its strategy process, key business processes and operating systems, policies and ethical guidelines. Siili does not have a separate due diligence process related to sustainability.

Risk management and internal controls over sustainability reporting

Sustainability reporting is carried out in compliance with Siili's principles and processes for regulatory reporting, risk management and internal control. Internal control for sustainability reporting has been organised based on the Group's governance model for internal control.

The assessment of risks related to sustainability reporting focuses particularly on reporting related to risks concerning the highest-materiality impacts, risks and opportunities based on the double materiality analysis as well as metrics involving the highest degree of calculation technical uncertainty. Prioritisation is made in connection with the risk assessment primarily based on the materiality of the sustainability theme being reported and secondarily on the related calculation technical uncertainty.

Siili's Board of Directors is informed of internal control for sustainability reporting as part of other reporting on internal control. The outcomes of internal control are monitored, and the control is steered by the Board of Directors and the Management Team.

The identified risks associated with sustainability reporting are the accuracy of the reported information and the timeliness of reporting. To ensure the accuracy of reported information and the timeliness of reporting, Siili is committed to continuously develop systematic collection and management of data and the assignment of roles and providing instructions for responsible personnel.

The Board of Directors, supported by its Audit Committee, holds ultimate responsibility for the proper organisation of internal control related to financial reporting. The Board of Directors reviews and adopts sustainability reporting in connection with the financial statements. The Chief Executive Officer (CEO), supported by the CFO and the General Counsel, is responsible for implementing internal control related to financial statement reports.

Strategy, business model and value chain

BUSINESS The Siili Group is an independent provider of information systems development services, which provides services to both private companies and the public sector. Siili serves its customers end-to-end in the planning, development, and maintenance of digital services. The Siili Group consists of the parent company Siili Solutions Plc and its subsidiaries. The subsidiaries are located in Finland, Poland, Germany, the USA, Hungary, the UK and the Netherlands. The domicile of Siili Solutions Plc is Helsinki, and its shares are listed on Nasdaq Helsinki Ltd. Companies of the Siili Group comply with local legislation and requirements in all of their activities.

Siili does not operate in the fossil fuel, natural gas, chemical production, controversial weapons or production of tobacco sectors, and the sale of its services is not banned in any certain markets.

2024 Financial Results

Total number of workforce with employment contracts by head count

STRATEGY Siili has placed artificial intelligence at the core of its strategy. Siili has three strategic priorities that strengthen its position as a leading company in the utilisation of artificial intelligence.

– Significant growth in Data and AI business: We expand our business in the growing market of data and generative AI, aiming to be the preferred partner for customers in the GenAI transformation. – Pioneer in AI-powered digital development: We reinforce our position as a pioneer in AI across the entire software development lifecycle, from design to implementation and maintenance. For Siili's customers, this means faster development cycles, and for Siili, improved productivity. – Community of top talent: We strengthen our strong corporate culture and continuous learning opportunities. Our goal is to be the most desirable community among digital development professionals.

Siili's competitive advantage is its ability to combine strong software development, AI, and industry expertise. This unique combination makes Siili a pioneer in utilizing and developing AI solutions and strengthening customers' competitiveness.

In its customer relationships, Siili focuses on large enterprises and the public sector in Finland, the UK, Germany, and the Netherlands. Siili will continue to strengthen its delivery capabilities by expanding its skill base both in Finland and Eastern Europe, for example in Poland and Hungary.

Siili's long-term financial goals for 2025–2028:

• Annual revenue growth of 20%, of which organic growth accounts for about half
• EBITA of 12% of revenue
• Keep the ratio of net debt to EBITDA below two
• Pay a dividend corresponding to 30–70% of net profit annually

VALUE CHAIN The majority (approximately 90%) of Siili's business consists of the sales of work, which means in practice that Siili's expert team complements the customer's own organisation in designing, developing and maintaining digital services. In addition, Siili implements projects for its customers and functions as a retailer of licences. In the sales of work, the value chain consists of just Siili and the customer. In these services, Siili utilises both its own personnel and experts working for Siili on an entrepreneurial contract.

In the sale of end-to-end solutions, the value chain may begin from the suppliers of licences and off-the-shelf software used in the project and proceed from the customers to the end users of digital services. In addition, the value chain includes a small group of service providers supporting Siili's administration and operations, such as suppliers of work equipment, landlords and providers of advisory, accounting and IT services.

The most critical resources in Siili's value chain are competent employees. Siili invests in its employees' development opportunities by providing assignments where they can enhance their expertise. Well-being at work is maintained and enhanced, among other things, by focusing on the work community and culture through various types of training, events and activities promoting well-being, putting an emphasis on management and leadership, facilitating flexible ways of working and providing comprehensive occupational health services. The recruitment of new employees is supported by Siili's strong reputation as an employer.

Interests and views of stakeholders

The Siili Group's key stakeholders are its employees and potential employees, customers, cooperation partners, shareholders and the capital markets, including supervisory authorities, financiers, the surrounding societies and the media.

Siili engages in dialogue with its stakeholders and develops its activities based on stakeholder feedback received. The most important stakeholders with the most significant impact on the strategy and business are customers and employees. Siili's strategy is formulated on the basis of current and future customer need, and based on the strategy, an action plan is formed to outline the development of Siili's business. At Siili, employees are encouraged to participate in the continuous development of the business and service offering. Employee well-being is also a strategic objective.

The views of the key stakeholders were considered in the double materiality analysis.

Stakeholder engagement:

Employee well-being is monitored by the Board of Directors at least quarterly, and themes related to employee satisfaction, well-being and development are discussed by the HR Committee on a regular basis, at least annually.

Material impacts, risks and opportunities and their interaction with strategy and business model

Siili has identified material impacts, risks and opportunities related to climate changes as well as social and governance topics. The material topics are presented in the adjacent table.

In the double materiality analysis, material negative and positive impacts, as well as risks, were identified related to climate change mitigation and greenhouse gas emissions. With respect to Siili's employees, the analysis identified positive impacts and risks related to working conditions and equal treatment, alongside negative impacts and opportunities related to equal treatment. A positive impact associated with corporate culture was identified.

Material impacts, risks and opportunities of sustainability

All material impacts, risks and opportunities are part of the ESRS disclosure requirements. Siili reports on the material impacts, risks and opportunities for the first time, so there are no changes in them compared to previous reporting.

In its strategy process of 2024, the Board of Directors considered the impacts, risks and opportunities determined based on the analysis. The well-being and competence of Siili's employees are a precondition for the business, and Siili's material impacts, risks and opportunities are closely tied to maintaining and enhancing them. A uniform corporate culture supports Siili's business operations. The material risks and opportunities defined based on the double materiality analysis did not result in significant financial impacts during 2024. No foreseeable financial impacts related to risks and opportunities are reported for 2024.

Description of the processes to identify and assess material impacts, risks and opportunities

IDENTIFICATION AND ASSESSMENT OF MATERIAL IMPACTS, RISKS AND OPPORTUNITIES Reported sustainability topics and sustainability metrics are based on a double materiality analysis carried out in two phases, the first one in 2022 and the second in spring 2024. The main objective of the double materiality analysis was to identify and assess the Company's impacts on the environment, society and governance, and to identify and assess the sustainability-related impacts, risks and opportunities that may affect the implementation of the Company's strategy and the achievement of its targets in the short, medium and long term. In assessing the impacts, risks and opportunities, attention was paid beyond Siili's own operations, to upstream and downstream operators in the value chain as well as other parties affected by the Company's operations. The assessment of Siili's own functions covered all market areas, i.e. Finland, the rest of Europe and North America.

In the first stage, stakeholders such as employees, subcontractors, customers and major shareholders were engaged in the analysis by soliciting their perspectives using both an online survey and interviews of a focus group selected among the stakeholders. Representatives of management, employees, Board of Directors, shareholders and customers, among others, were engaged in the interviews.

During the second stage, the assessment was expanded based on the requirements of the ESRS standard. The double materiality analysis of 2024 included a review of all topics listed in the Directive and with the intent to fully comply with the application requirements as well. With a view to the nature of Siili's business, there was no reason to focus on certain areas, business relations or actions in its own operations or those in the value chain.

The classification of sustainability impacts, risks and opportunities was based on a division into subtopics, i.e. topics, subtopics and sub-sub-topics. The sustainability topics were mapped in the short term, i.e. the past year, the medium term covering 1–5 years and the long term extending longer than 5 years. The total number of identified impacts, risks and opportunities related to the topics was 30, of which 10 concerned the environment, 16 pertained to social responsibility and 4 to governance. These included 13 risks and 8 opportunities.

The impacts, risks and opportunities were assessed and prioritised by estimating their severity, which reflected their scope, and for negative impacts, their remediability and financial materiality. As regards the risks and opportunities related to the topics, the estimated severity also reflected their probability of occurrence. Risks associated with human rights were deemed material due to the severity of the topic, even if the probability was low. The medium- and long-term risk associated with climate change mitigation was prioritised as a sustainability risk, and it was also deemed material based on stakeholders' information need.

The scale of measurement for severity, scale and remediability was a numerical assessment ranging from 1 to 5, while the estimated financial impact of Siili's various risk categories ranged from very low to very high. On this scale, a very low impact means an impact of less than 1% on revenue or profitability, an impact of 2–5% is regarded as medium and an impact of 5–10% as high. A very significant impact means an impact of over 10% on revenue or profitability. At a threshold value of 2, there were a total of 13 material impacts and 7 financially material impacts.

The process was carried out through workshops involving members of the Management Team and responsible personnel from various functions who presented stakeholders' views.

The results of the double materiality analysis emphasised in particular social responsibility and its sub-topics: equal treatment, working conditions and diversity. Another topic found relevant was corporate culture, which is supported by corporate governance, policies and processes. As regards environmental responsibility, the most relevant topics proved to be climate change mitigation and greenhouse gas emissions. Based on the materiality analysis, topics material from the perspective of the Company's operations, services and stakeholders were chosen.

Siili's Board of Directors confirmed the material topics in its meeting on 12 August 2024. Towards the end of 2024, preparations were launched for reporting under the Accounting Act. In this context, the datapoints to be reported on each topic were determined based on the Sustainability Reporting Standards and consulting EFRAG's Implementation Guidance, and the collection of required data was initiated.

Going forward, Siili will review its double materiality analysis on an annual basis as part of its regular business development. Siili will update and complement the double materiality analysis more extensively every other year. The identification, assessment and management process of sustainability-related impacts, risks and opportunities will be integrated into the overall risk management process. The integration of the targets and metrics to be determined based on the double materiality analysis into Siili's management system will be planned and implemented during the financial year 2025. The double materiality analysis will be reviewed during H2/2025.

ASSESSMENT OF OTHER ENVIRONMENTAL TOPICS Given the nature of Siili's business, which is based on the sale of work, environmental topics pertaining to degradation, water and marine resources, biodiversity, ecosystems, resource use and the circular economy were deemed not material with respect to Siili's business and value chain. Consequently, they were excluded from a more thorough assessment after an initial discussion. As a result, Siili did not screen or evaluate the locations of its sites, its business, assets or value chain from the perspective of impacts, risks, opportunities and dependencies concerning degradation, water and marine resources, biodiversity, ecosystems, resource use and the circular economy.

Siili's sites are offices, and therefore their location in or near biodiversity-sensitive areas was not specifically evaluated. In the double materiality analysis, Siili did not evaluate dependencies, systemic risks, transition risks, physical risks or opportunities related to biodiversity and ecosystems. Due to the nature of its business, Siili did not find it necessary to implement mitigation measures related to biodiversity. No separate consultations were conducted with respect to environmental topics.

Disclosure requirements in ESRS covered by the undertaking's sustainability statement

The material disclosure requirements and datapoints reported in Siili's sustainability statement have been determined in accordance with EFRAG Implementation Guidance 3 and the ESRS. The datapoints to be reported were determined with a view to Siili's business and the outcome of the double materiality analysis, based on the topic-specific standards, sub-topics and sub-sub-topics material to the Company. The evaluation process concerning the materiality of the topics, including the materiality threshold, is described in the IRO-1 section.

List of disclosure requirements complied with:

Transition plan for climate change mitigation

Siili's business and strategy support sustainable development because IT solutions can be used to reduce the environmental burden and the use of resources. Furthermore, Siili places a special emphasis on its social responsibility for its own employees and those in the value chain. One of the three strategic goals in Siili's strategy is to be a community of top talent. Siili develops its corporate culture and continuous learning opportunities aiming to be the most attractive community among digital development professionals.

Siili has not set any sustainability-related targets for the financial year 2024, but it will evaluate and establish these targets in 2025.

Key focus areas based on double material analysis - ENVIRONMENTAL

• Drive sustainable and responsible IT services
• Climate change
• Carbon footprint

Key KPIs and targets Reduce emissions by 2030

• Scope 1 & 2 emissions = 0
• Scope 3 emissions reduced by 20% compared to 2022

Siili has taken the results of the double materiality analysis into account in its strategy process. When renewing our strategy in 2024, we also took into account the results of the double materiality analysis and the views of key stakeholders, customers and employees, in our strategy work.

Siili has started defining sustainability goals and indicators, and Siili's board of directors will confirm the sustainability goals during 2025.

Policies related to climate change mitigation and adaptation

Siili does not have specific climate-related policies. Siili's approach to climate change mitigation is integrated into its overall sustainability approach and business strategy. The company's strategy supports sustainable development as IT solutions can be used to reduce environmental burden and resource use.

Siili's business model, which is primarily based on software development services rather than physical products, inherently has a lower environmental impact than traditional manufacturing businesses. The company operates primarily through office locations and does not operate in fossil fuel, natural gas, chemical production, controversial weapons or tobacco production sectors.

Siili has identified climate change mitigation as a material topic through its double materiality analysis and will establish formal climate-related policies and targets during 2025 as part of its sustainability program development.

Actions and resources in relation to climate change policies

Siili's actions related to climate change are currently integrated into its business operations and strategy. As a software development company, Siili's primary environmental impact comes from its office operations and employee travel.

Current actions include:

• Operating primarily in office environments with lower environmental impact compared to manufacturing operations
• Focus on digital solutions that can help customers reduce their environmental burden
• Employee awareness and engagement through the double materiality analysis process
• Integration of sustainability considerations into strategic planning

Siili will develop more specific climate-related actions and resource allocation plans during 2025 as part of establishing formal sustainability targets. The company has committed to reducing Scope 1 & 2 emissions to zero and Scope 3 emissions by 20% compared to 2022 levels by 2030.

The resources for implementing climate actions will be determined as part of the sustainability program to be established in 2025, with responsibility assigned across the organization including the Board of Directors, Management Team, and operational units.

Targets related to climate change mitigation and adaptation

Siili's Climate Targets by 2030:

Siili has identified climate change mitigation as a material sustainability topic through its double materiality analysis. The company has committed to ambitious emission reduction targets as part of its sustainability strategy.

Siili has not set any sustainability-related targets for the financial year 2024, but it will evaluate and establish detailed targets, including interim milestones and action plans, in 2025. The Board of Directors will confirm the sustainability goals during 2025.

The company will develop specific implementation plans, metrics, and monitoring systems to track progress toward these targets as part of its sustainability program development in 2025. These targets will be integrated into Siili's overall business strategy and management systems.

Energy consumption and mix

Siili has not yet established comprehensive energy consumption reporting systems. As this is the company's first sustainability statement under ESRS, detailed energy consumption data for 2024 is not available.

Siili operates primarily in office environments across multiple countries (Finland, Poland, Germany, USA, Hungary, UK, and Netherlands). The company's energy consumption is primarily related to:

• Office heating, cooling, and lighting
• IT equipment and servers
• Employee devices and workstations

As part of its sustainability program development in 2025, Siili will implement systematic energy consumption monitoring and reporting. This will include establishing baseline measurements and tracking progress toward the company's target of zero Scope 1 & 2 emissions by 2030.

Given the nature of Siili's business as a software development company operating primarily in office environments, the company does not operate in high climate impact sectors and therefore detailed energy intensity metrics by sector are not applicable.

Gross Scopes 1, 2, 3 and Total GHG emissions

Siili has not yet established comprehensive GHG emissions reporting systems. As this is the company's first sustainability statement under ESRS, detailed emissions data for 2024 is not available.

Siili operates as a software development company with operations primarily in office environments across Finland, Poland, Germany, USA, Hungary, UK, and Netherlands. The company's main sources of emissions are expected to include:

Scope 1 (Direct emissions):

• Company vehicles (if any)
• On-site fuel combustion

Scope 2 (Indirect emissions from energy):

• Electricity consumption in offices
• Heating and cooling systems

Scope 3 (Other indirect emissions):

• Business travel
• Employee commuting
• IT equipment and services
• Office leases and operations

Siili has committed to achieving zero Scope 1 & 2 emissions and reducing Scope 3 emissions by 20% compared to 2022 levels by 2030. The company will establish baseline measurements and implement systematic emissions tracking as part of its sustainability program development in 2025.

The company will develop emissions intensity metrics and reporting systems to monitor progress toward its climate targets.

Policies related to own workforce

SOCIAL RESPONSIBILITY Siili's key themes with an impact on the employee experience are remuneration, competence development, well-being, culture, community spirit and meaningful customer projects. Employee well-being is also a strategic objective. Responsible and ethical operations as well as compliance with laws form the foundation of Siili's business.

Key focus areas based on double material analysis - SOCIAL

• With AI in our core, build the best community for digital development professionals
• Work-life balance
• Equal treatment
• Development opportunities

Key metrics from personnel survey

• eNPS, target 65 by 2028
• Engagement, target 75 for 2025

Human rights policy commitments Siili's operations are based on respect for human rights and compliance with applicable laws and regulations. The company's Code of Conduct includes provisions related to human rights, including non-discrimination and equal treatment of all employees.

Due diligence policies on fundamental International Labour Organisation Conventions Siili complies with fundamental ILO conventions through its adherence to local labor laws and regulations in all countries where it operates (Finland, Poland, Germany, USA, Hungary, UK, and Netherlands). The company ensures compliance with local employment legislation and practices.

Processes and measures for preventing trafficking in human beings Siili has established policies and processes to prevent any involvement in human trafficking through its recruitment processes, supplier relationships, and business operations. The company conducts due diligence on its suppliers and business partners.

Workplace accident prevention policy or management system Siili maintains comprehensive occupational health and safety policies and systems across all its operations. This includes providing comprehensive occupational health services and ensuring safe working environments for all employees. The company focuses on promoting well-being at work through various training, events and activities.

Processes for engaging with own workforce and workers' representatives about impacts

Siili engages with its workforce through multiple channels and processes:

Employee representation Siili's employees are represented in the management team for the Finnish business by a staff representative. Siili does not have employee representation in other administrative or supervisory bodies in other countries.

Employee engagement channels:

• Growth discussions with individual employees
• Vibemetrics tool for continuous feedback
• Internal meetings and information events
• Personnel representation in Finnish Management Team
• Company events and parties
• Internal communications channels (e.g. Slack)
• Employee Sounding Board for feedback and input
• Whistleblowing channel for concerns and complaints

Key engagement topics with employees:

• Development opportunities and career growth
• Well-being and support by working community
• Work-life balance initiatives
• Rewarding and equal remuneration
• Competence development and training opportunities

Regular monitoring: Employee well-being is monitored by the Board of Directors at least quarterly, and themes related to employee satisfaction, well-being and development are discussed by the HR Committee on a regular basis, at least annually.

The company conducts regular employee surveys to measure engagement and satisfaction, with targets of eNPS 65 by 2028 and engagement score of 75 for 2025.

Processes to remediate negative impacts and channels for own workforce to raise concerns

Grievance/complaints handling mechanisms Siili has established multiple channels for employees to raise concerns and report issues:

• Whistleblowing channel: Available for employees to report concerns about misconduct, violations of policies, or other serious issues
• Internal communications channels: Including Slack and other platforms for raising day-to-day concerns
• Employee Sounding Board: Formal mechanism for employee feedback and raising concerns
• Growth discussions: Regular one-on-one meetings between employees and management
• Management representation: Personnel representation in Finnish Management Team
• HR Committee oversight: The Board's HR Committee monitors employee satisfaction and addresses systemic issues

Remediation processes Siili is committed to addressing any negative impacts on its workforce through:

• Investigation of all reported concerns
• Corrective action plans where issues are identified
• Follow-up monitoring to ensure effectiveness of remedial actions
• Protection of whistleblowers and those raising concerns
• Continuous improvement of policies and processes based on feedback

The company's Code of Conduct provides the framework for ethical behavior and includes provisions for reporting and addressing violations. All employees are expected to report concerns and the company ensures that no retaliation occurs against those who report issues in good faith.

Taking action on material impacts on own workforce

Siili has identified several material impacts related to its own workforce through its double materiality analysis and takes the following actions:

Positive impacts being advanced:

Working conditions:

• Full freedom of association: Employees have diverse opportunities to participate in Siili's decision-making through employee representation, sounding boards, and regular feedback mechanisms
• Flexible working arrangements: Implementation of working time tracking and flexible working hours to support work-life balance
• Work-life balance: Active promotion of employee well-being through various programs, events, and flexible work arrangements

Equal treatment and opportunities:

• Competence development: Continuous investment in employee development through training programs, particularly in AI and data expertise (43% increase in data and AI experts in 2024)
• Workforce diversity: Enhancement of workforce diversity, though acknowledging challenges in the IT sector
• Safe working environment: Providing a safe working environment for all employees across all locations

Actions to address risks:

• International collaboration practices: Working to apply employee-management collaboration practices used in Finland to other operating countries
• Employer brand protection: Prioritizing diversity development to maintain strong employer reputation (achieved 10th place in Young Professional Attraction Index survey by Academic Work in 2024)

Effectiveness monitoring:

• Regular employee satisfaction surveys with specific targets (eNPS target of 65 by 2028, engagement target of 75 for 2025)
• Quarterly monitoring by Board of Directors
• Annual review by HR Committee
• Continuous feedback through multiple channels

Siili's strategic priority to be a "community of top talent" directly addresses these material impacts, with actions focused on strengthening corporate culture, providing continuous learning opportunities, and maintaining employee well-being.

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Employee engagement and satisfaction targets:

Strategic workforce objectives:

• Community of top talent: Be the most desirable community among digital development professionals
• Competence development: Continuous enhancement of employee skills, particularly in AI and data (achieved 43% increase in data and AI experts in 2024)
• Work-life balance: Maintain and improve flexible working arrangements and employee well-being programs
• Diversity and inclusion: Continue efforts to enhance workforce diversity while addressing IT sector challenges

Risk management targets:

• Maintain strong employer brand and reputation
• Ensure applicability of best practices across all operating countries
• Zero tolerance for discrimination or unsafe working conditions

Implementation approach: Siili will establish detailed sustainability goals and indicators in 2025, with the Board of Directors confirming specific targets and action plans. The integration of these targets into Siili's management system will be planned and implemented during 2025.

Monitoring and review:

• Quarterly monitoring by Board of Directors
• Annual comprehensive review by HR Committee
• Regular employee surveys and feedback collection
• Progress reporting in annual sustainability statements

These targets support Siili's strategic priority of being a community of top talent and directly address the material impacts, risks, and opportunities identified through the double materiality analysis.

Characteristics of the undertaking's employees

Total workforce by employment contract:

Workforce changes:

• Average number of employees during 2024: 975 (compared to 1,026 in 2023)
• Year-end employees: 942 (compared to 1,007 in 2023)
• Net decrease: 65 employees (-6.5%)
• Previous year decrease: 38 employees (-3.6%)

Geographic distribution: Siili operates in 8 countries with offices in Helsinki, Tampere, Turku, Lappeenranta, Jyväskylä, Oulu, Kuopio, Seinäjoki, Joensuu (Finland), London (UK), Amsterdam (Netherlands), Berlin, Stuttgart (Germany), Vienna (Austria), Budapest (Hungary), Szczecin, Wroclaw (Poland), New York, Detroit (USA).

Business focus: Approximately 90% of Siili's business consists of sales of work, meaning Siili's expert teams complement customers' organizations in designing, developing and maintaining digital services. The company serves large enterprises and public sector clients primarily in Finland, UK, Germany, and the Netherlands.

Management team composition: At the end of 2024, Siili's Management Team consisted of 5 members: Tomi Pienimäki (CEO), Aleksi Kankainen (CFO), Taru Salo (CPO), Andras Tessenyi (CEO, Supercharge), and Maria Niiniharju (VP Private Business, joined November 1, 2024).

Characteristics of the undertaking's non-employee workers

Siili utilizes both its own personnel and experts working for the company on an entrepreneurial contract basis in delivering its services. In the sales of work, which comprises approximately 90% of Siili's business, the company complements customers' own organizations using both employed staff and contracted experts.

Types of non-employee workers:

• Experts working on entrepreneurial contracts
• Subcontractors providing specialized services
• External consultants for specific projects

Subcontracting costs:

The use of subcontracting was reduced from the previous year as part of efficiency improvement measures and capacity optimization.

Value chain integration: Non-employee workers are integrated into Siili's value chain primarily in the delivery of customer projects. These arrangements allow Siili to:

• Access specialized expertise for specific customer needs
• Scale capacity flexibly based on project demands
• Maintain cost efficiency while delivering high-quality services

Subcontractors and non-employee workers are subject to the same quality standards and ethical guidelines as employed staff, ensuring consistent service delivery and compliance with Siili's Code of Conduct.

Collective bargaining coverage and social dialogue

Siili operates in multiple countries with different employment law frameworks and collective bargaining traditions:

Finland:

• Employees are covered by applicable collective agreements in the Finnish IT sector
• Employee representation exists in the Finnish Management Team through a staff representative
• Strong tradition of employee-management collaboration and social dialogue

Other operating countries:

• Operations in Poland, Hungary, Germany, USA, UK, Netherlands, and Austria follow local employment legislation and practices
• Compliance with local collective bargaining arrangements where applicable
• Application of Finnish collaboration practices to other countries identified as a risk/opportunity in materiality analysis

Social dialogue mechanisms:

• Employee representation in Finnish Management Team
• Employee Sounding Board for feedback and dialogue
• Regular growth discussions between employees and management
• Internal meetings and information events
• Multiple communication channels (Slack, internal communications)
• Whistleblowing channel for raising concerns

Challenges and opportunities: Siili has identified the "applicability of employee-management collaboration practices used in Finland to other operating countries" as both a risk and an area for development. The company is working to extend best practices in employee relations and social dialogue across all its international operations.

Employee well-being is monitored by the Board of Directors at least quarterly, and employee satisfaction, well-being and development themes are discussed by the HR Committee regularly, demonstrating the company's commitment to maintaining effective social dialogue across all locations.

Diversity metrics

Board and Management diversity:

Board of Directors gender diversity:

• Gender diversity ratio (female to male): 0.4
• 100% of Board members are independent of the Company
• 80% of Board members are independent of the largest shareholders

Workforce diversity challenges and opportunities: Siili has identified several diversity-related impacts through its double materiality analysis:

Positive impacts:

• Enhancement of workforce diversity: Ongoing efforts to improve diversity across the organization
• Safe working environment: Providing a safe working environment for all employees regardless of background

Challenges identified:

• IT sector diversity challenges: Recognition that increasing diversity in the IT sector presents inherent challenges
• Employer brand risk: Risk of deterioration of employer brand if diversity development is not adequately prioritized

Strategic commitment: Diversity and inclusion are part of Siili's strategic priority to be a "community of top talent" and create the most desirable workplace for digital development professionals. The company recognizes that building diverse teams is essential for innovation and competitive advantage in the AI and technology sector.

Siili achieved 10th place in the Young Professional Attraction Index survey by Academic Work in 2024, demonstrating its appeal as an employer, and continues to work on enhancing diversity as part of its broader talent strategy.

Detailed diversity metrics by various categories will be developed as part of the sustainability program implementation in 2025.

Training and skills development metrics

2024 Training and Development Achievements:

AI and Data Expertise Development:

• 43% increase in the number of data and AI experts compared to previous year
• Three-level training programme in artificial intelligence launched for consultants
• Published a handbook for AI-powered developers
• Continuous development of personnel's AI expertise through both training and recruitment

Strategic focus on competence development: Siili's strategic priority as a "Pioneer in AI-powered digital development" requires continuous investment in employee competence development. The company has made significant investments in developing AI and data capabilities across the organization.

Training approach:

• Continuous learning: Part of Siili's strategy to be a "community of top talent"
• On-the-job development: Providing assignments where employees can enhance their expertise
• Formal training programs: Structured AI training programmes
• Knowledge sharing: Development of internal resources like AI development handbook

Development opportunities as strategic pillar: Employee development opportunities are identified as one of the key themes impacting employee experience, alongside remuneration, well-being, culture, community spirit and meaningful customer projects.

Customer project learning: Employees gain valuable experience through meaningful customer projects, particularly in AI and data transformation initiatives, allowing them to apply new skills in real-world scenarios.

Future development: Detailed training metrics including hours of training, training categories, and employee participation rates will be established as part of the sustainability program development in 2025. The company will continue to prioritize competence development as a core element of its talent strategy and competitive advantage in AI transformation.

Work-life balance metrics

Work-life balance initiatives and positive impacts identified:

Siili has identified work-life balance of employees as a positive impact through its double materiality analysis, recognizing this as a key area of strength and continued focus.

Key work-life balance measures:

Flexible working arrangements:

• Working time tracking and flexible working hours: Implemented as a positive impact supporting employee autonomy
• Flexible ways of working: Part of comprehensive well-being program
• Location flexibility: Operations across multiple countries allowing for diverse working arrangements

Well-being support systems:

• Comprehensive occupational health services: Provided across all locations
• Various training, events and activities promoting well-being: Regular programming to support employee wellness
• Focus on work community and culture: Building supportive work environment
• Management and leadership emphasis: Leadership development that supports work-life balance

Strategic importance: Work-life balance is one of the key themes with impact on employee experience, alongside:

• Remuneration
• Competence development
• Culture and community spirit
• Meaningful customer projects

Employee satisfaction metrics:

Recognition: Siili achieved 10th place in the Young Professional Attraction Index survey by Academic Work in 2024, demonstrating the effectiveness of its work-life balance and employee well-being initiatives.

Future development: Specific quantitative work-life balance metrics (such as flexible work arrangement usage, overtime hours, leave utilization) will be developed as part of the sustainability program implementation in 2025.

Compensation metrics (pay gap and total compensation)

Remuneration approach: Rewarding and equal remuneration is identified as one of the key topics in stakeholder engagement with employees and one of the main themes impacting employee experience.

Governance of remuneration: The remuneration policy for Siili's governing bodies is defined by principles governing the remuneration of the Company's Board of Directors, chief executive officer and deputy CEO. The policy has been prepared in accordance with:

• Shareholder Rights Directive ((EU) 2017/828)
• Finnish Limited Liability Companies Act (264/2006, as amended)
• Securities Markets Act (746/2012, as amended)
• Decree 608/2019 of the Ministry of Finance
• Corporate Governance Code

Remuneration objectives: The objective of the remuneration policy is to promote:

• Company's strategy
• Long-term financial success
• Sustainable growth of shareholder value

Executive compensation: Detailed information on executive remuneration is provided in the separate Remuneration Report and Remuneration Policy documents.

Pay equity commitment: Siili is committed to equal remuneration practices across all employee groups and geographic locations. The company operates in multiple countries (Finland, Poland, Germany, USA, Hungary, UK, Netherlands) and ensures compliance with local compensation regulations and standards.

Future development: Specific pay gap metrics (including gender pay gap analysis) and comprehensive compensation metrics will be established and reported as part of the sustainability program development in 2025. This will include:

• Unadjusted gender pay gap analysis
• CEO pay ratio metrics
• Compensation equity analysis across different employee groups and locations

The HR Committee of the Board of Directors prepares principles underlying performance and result criteria of remuneration schemes and monitors their achievement, ensuring fair and equitable compensation practices across the organization.

Incidents, complaints and severe human rights impacts

Human rights framework: Siili's operations are based on respect for human rights and compliance with applicable laws and regulations. The company's Code of Conduct includes provisions related to human rights, including non-discrimination and equal treatment of all employees.

Risk assessment: Through its double materiality analysis, Siili has assessed human rights risks across its operations. Risks associated with human rights were deemed material due to the severity of the topic, even if the probability was low given the nature of Siili's business and operating locations.

Material human rights topics identified:

• Risk of incidents of forced labour: Assessed as part of the ESRS framework
• Risk of incidents of child labour: Assessed as part of the ESRS framework
• Non-respect of UNGPs on Business and Human Rights and OECD Guidelines: Monitored and prevented through company policies

Grievance mechanisms:

• Whistleblowing channel: Available for reporting concerns about violations
• Employee Sounding Board: Formal mechanism for raising concerns
• Multiple communication channels: Internal channels for reporting issues
• Management representation: Personnel representation in Finnish Management Team

Prevention measures:

• Code of Conduct: Comprehensive ethical guidelines covering human rights
• Due diligence processes: For suppliers and business partners
• Compliance with local laws: In all operating countries (Finland, Poland, Germany, USA, Hungary, UK, Netherlands)
• Training and awareness: Employee education on human rights and ethical conduct

2024 Reporting: For 2024, Siili reports no material incidents of discrimination, human rights violations, or severe human rights impacts. The company maintains zero tolerance for such incidents and has established processes to investigate and address any concerns that may arise.

Monitoring and improvement: The company continuously monitors human rights compliance through:

• Regular review of policies and procedures
• Employee feedback mechanisms
• Compliance audits and assessments
• Integration of human rights considerations into business processes

Detailed incident tracking and human rights metrics will be further developed as part of the sustainability program implementation in 2025.

Business conduct policies and corporate culture

Corporate Culture as Strategic Asset: Siili has identified its "strong and unique corporate culture" as a positive impact across its entire value chain (upstream, own operations, and downstream) through its double materiality analysis. This corporate culture is supported by corporate governance, policies and processes.

Key focus areas based on double material analysis - GOVERNANCE

• Ensure good governance
• Company culture (including Code of Conduct, compliance and ethics, HR)

Key targets

• 0 security incidents
• 0 Code of Conduct breaches

Code of Conduct and Ethics: Siili's operations are based on responsible and ethical conduct and compliance with laws forming the foundation of the business. The Board of Directors adopts Siili's Code of Conduct steering company activities and detailed instructions based on it.

The Company's operating procedures are based on Siili's Code of Conduct and policies adopted by the Board of Directors. The Code of Conduct includes provisions related to:

• Human rights and non-discrimination
• Equal treatment of all employees
• Ethical business practices
• Compliance with applicable laws and regulations
• Anti-corruption and anti-bribery measures

Corporate Governance Framework: Siili's corporate governance is based on:

• Legislation in force in Finland
• Rules and regulations issued for listed companies by Nasdaq Helsinki
• Finnish Financial Supervisory Authority (FIN-FSA) regulations
• Siili's Articles of Association
• Finnish Corporate Governance Code for listed companies

Governance principles: Siili's governance and control are rooted in:

• Honesty: Transparent and truthful business conduct
• Accountability: Clear responsibility for decisions and actions
• Equality: Fair treatment of all stakeholders
• Transparency: Open communication and reporting

Strategic Culture Development: One of Siili's three strategic priorities is to be a "Community of top talent" which includes:

• Strengthening corporate culture
• Continuous learning opportunities
• Being the most desirable community among digital development professionals
• Focus on employee well-being and development

Culture measurement and monitoring:

• Regular employee satisfaction surveys
• Employee Net Promoter Score (eNPS) target of 65 by 2028
• Employee engagement score target of 75 for 2025
• Recognition: 10th place in Young Professional Attraction Index survey by Academic Work in 2024

Risk management: Siili has established targets for zero security incidents and zero Code of Conduct breaches, demonstrating its commitment to maintaining high standards of business conduct and corporate culture.

The company's culture and business conduct policies will continue to be developed and monitored as part of the sustainability program implementation in 2025.